Questions and Answers

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  • 1 - 15 of 15
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Coal Combustion; Coincidental Manufacturing; Combustion Byproducts3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Acids
<div style="visibility:hidden">19191 19-191 191 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Acids Coal Combustion; Coincidental Manufacturing (Byproduct; Coincidental Manufacture); Combustion Byproducts 191. A covered facility heats coal to approximately 2,000°F to drive off the volatiles from the coal to produce an activated carbon product. Is this activity considered coal combustion such that Section 313 metal compounds are manufactured in this operation?Generally, activation of carbon or other organic material involves a two-step process. The first step consists of carbonizing the organic material, which is generally carried out by subjecting the material to temperatures in the range of 500 to 700°C (approximately 930 to 1,300°F). The second step, the activation process, may be chemically performed or it may also be conducted using temperatures typically in the 750 to 1,000°C range (approximately 1,380 to 1,850°F). Both activities occur at temperatures that are below the temperature posed in the question. In any case, while these are high temperatures, these ranges are not equivalent to the temperatures that take place during combustion. Based on available information, the temperature described in the question is not high enough to cause coal combustion. For example, furnaces may operate at temperatures above 1,400°C (approximately 2,550°F). The temperature described in the question may not result in many of the chemical conversions, such as the transformation of metal compounds, which are expected to occur during combustion. However, these temperatures may result in some conversions and the facility would need to determine what takes place based on their best available information and report as necessary.</div></b><div style="visibility:hidden"></div></b>-
Acids; Neutralization; Release Reporting; pH3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Acids
<div style="visibility:hidden">19498 19-498 498 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Acids Acids (Acid Aerosol); Neutralization; Release Reporting; pH 498. A strong mineral acid solution is neutralized (i.e., the pH of the solution is adjusted to pH 6 or greater) before release to surface waters. How do we report this release on the Form R?For purposes of EPCRA section 313 reporting, a discharge of pH 6 or above contains no reportable amount of mineral acid. The facility owner/operator should report zero, not NA, in Part II, Section 5.3 of the Form R.</div></b><div style="visibility:hidden"></div></b>-
Acid Aerosol; Hydrochloric Acid; Sulfuric Acid; Treatment for Destruction3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Acids
<div style="visibility:hidden">19499 19-499 499 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Acids Acid Aerosol; Hydrochloric Acid; Sulfuric Acid; Treatment for Destruction (Incineration) 499. A waste stream containing aerosol forms of hydrochloric and sulfuric acid goes up a stack. Before exiting the stack, the waste stream passes through a scrubber where the acid aerosols are captured in an aqueous solution. How is this to be reported under Section 313?When a scrubber is used to remove sulfuric or hydrochloric acid aerosols prior to or in a stack, the acid aerosols are usually converted to the non-aerosol form. The non-aerosol forms of sulfuric and hydrochloric acid are not reportable under EPCRA section 313 because the qualifier to the sulfuric acid and hydrochloric acid listing includes only acid aerosol forms. Sulfuric and hydrochloric acid as discrete chemicals have not actually been destroyed by the scrubber, but the form of these acids reportable under EPCRA section 313 has been destroyed. Therefore, since sulfuric or hydrochloric acid aerosols removed by scrubbers are converted to non-reportable forms, the quantity removed by the scrubber can be reported as having been treated for destruction. However, all of the sulfuric acid or hydrochloric acid aerosols that are produced prior to or after the scrubber count towards that manufacturing threshold, and any acid aerosols that are not removed by the scrubber and continue out of the stack must be reported as a release to air.</div></b><div style="visibility:hidden"></div></b>-
Acid Aerosol; Acids; Sulfuric Acid3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Acids
<div style="visibility:hidden">19500 19-500 500 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Acids Acid Aerosol; Acids (Acid Aerosol); Sulfuric Acid 500. A covered facility subject to EPCRA section 313 generates aerosol sulfuric acid in excess of 25,000 pounds in a calendar year. The aerosol sulfuric acid passes through a scrubber that removes and condenses the aerosol sulfuric acid. The resulting liquid sulfuric acid then undergoes chemical conversion in an on-site treatment unit. How must the owner or operator account for these activities in Part II, Sections 7 and 8 of the Form R?When a scrubber is used to remove sulfuric acid aerosols prior to entering or in a stack, the acid aerosols are usually converted to the non-aerosol form. The non-aerosol forms of sulfuric acid are not reportable under EPCRA section 313 because the qualifier to the sulfuric acid listing includes only acid aerosol forms (40 CFR Section 372.65). Sulfuric acid is not actually being destroyed by the scrubber, but the form of sulfuric acid that is reportable under EPCRA section 313 is being destroyed. Therefore, since sulfuric acid aerosols removed by scrubbers are converted to a non-reportable form, the quantity removed by the scrubber can be reported as having been treated for destruction under Part II, Section 7 and should be included in Section 8.6, (Quantity Treated On-Site). Since the condensed sulfuric acid (i.e., the liquid sulfuric acid) is a non-aerosol form, it is not reportable under EPCRA section 313 and no reporting of other waste management activities for these non-aerosol forms is required.</div></b><div style="visibility:hidden"></div></b>-
Acid Aerosol; Acids; Reuse3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Acids
<div style="visibility:hidden">19501 19-501 501 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Acids Acid Aerosol; Acids (Acid Aerosol); Reuse 501. How are sulfuric and hydrochloric acid aerosols that are generated over and over again in acid reuse systems to be reported under Section 313?When solutions of sulfuric acid and hydrochloric acid are aerosolized the manufacture of a listed chemical (sulfuric acid or hydrochloric acid aerosols) has occurred. This is a result of the qualifier to the sulfuric acid and hydrochloric acid listings, which excludes non-aerosol forms and limits the reporting to aerosol forms only. The addition of the acid aerosol qualifier has an impact on certain processes that, prior to the addition of the qualifier, would not have been considered as the manufacturing of a listed chemical. Acid reuse systems that use aqueous solutions of sulfuric acid or hydrochloric acid to generate acid aerosols, use the acid aerosols, condense them back into solution, and then reuse the acid solution again and again are impacted by the addition of the acid aerosol qualifiers. In such processes, the continuous reuse of the acid solutions generates very large quantities of acid aerosols that technically should be counted towards the manufacture (the generation of the acid aerosol is the manufacture of sulfuric or hydrochloric acid (acid aerosol)) and otherwise use thresholds. This may result in many facilities greatly exceeding the manufacture and otherwise use reporting thresholds that, prior to the addition of the qualifier, would not have exceeded thresholds. While it is technically correct to apply all of the quantities of acid aerosols generated in such systems towards the manufacture and otherwise use reporting thresholds, EPA did not intend to increase the reporting burden as a result of the addition of the acid aerosol qualifiers. In addition, under EPA’s general approach to reuse systems, a listed toxic chemical is not counted toward thresholds each time it is reused but only once per reporting period. This approach would apply to sulfuric acid or hydrochloric acid reuse systems were it not for the aerosol qualifiers. Therefore, EPA is providing the following guidance to reduce the reporting burden for covered facilities that operate such processes and to bring the treatment of such systems into alignment with EPA’s general approach to reuse. Rather than having covered facilities count all quantities of acid aerosol generated in such systems towards the manufacture and otherwise use thresholds, EPA will allow facilities to apply the total volume of acid in these systems only once to these thresholds. For example, if an acid reuse system starts the year with 2,000 pounds of acid and 500 pounds is added during the year then the total amount applied towards acid aerosol thresholds would be 2,500 pounds. This reflects a one-time per year counting of all of the acid molecules as being in the acid aerosol form rather than counting them over and over again each time the acid aerosol form is generated and subsequently used. Since in these acid reuse systems the acid aerosols are manufactured and then otherwise used the 10,000-pound otherwise use threshold would be the threshold that triggers reporting from such systems. This guidance applies only to acid reuse systems and the reporting of sulfuric acid and hydrochloric acid aerosols under EPCRA section 313. This guidance does not apply to any other types of processes or to any other listed chemical.</div></b><div style="visibility:hidden"></div></b>-
Activity Threshold; Reuse3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Acids
<div style="visibility:hidden">19502 19-502 502 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Acids Activity Threshold (Threshold Determination); Reuse 502. In 1999, a covered facility’s sulfuric acid reuse system starts the year with 4,000 pounds of sulfuric acid, and the facility adds 8,000 pounds to the system. How should the facility make threshold determinations for sulfuric acid (acid aerosol)?The method for estimating amounts of sulfuric acid (acid aerosol) and hydrochloric acid (acid aerosol) for threshold purposes is unique as compared to other listed toxic chemicals. In the above question, the facility should apply 12,000 pounds towards the manufacturing and otherwise use thresholds. To determine the amount manufactured in an acid reuse system, the facility should calculate the total volume of acid in the system. The total volume of acid is the sum of the reporting year's starting amount and the amount added during the reporting year. Because all the sulfuric acid aerosol manufactured is subsequently otherwise used, the 12,000 pounds are also applied to the otherwise use threshold of 10,000 pounds. Therefore, the facility exceeds the otherwise use threshold and must file a Form R or Form A. Facilities are also directed to refer to the Guidance for Reporting Sulfuric Acid (EPA-745-R-97-007; November 1997).</div></b><div style="visibility:hidden"></div></b>-
Acid Aerosol; Acids; Sulfuric Acid3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Acids
<div style="visibility:hidden">19503 19-503 503 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Acids Acid Aerosol; Acids (Acid Aerosol); Sulfuric Acid 503. Would a sulfuric acid drip system that is in contact with an ore leach pile (described as analogous to a gardener's drip hose) be manufacturing sulfuric acid in an aerosol form?No, the sulfuric acid does not become airborne; so it is not an aerosol form of sulfuric acid and, therefore, not a reportable toxic chemical under EPCRA section 313 (40 CFR Section 372.65).</div></b><div style="visibility:hidden"></div></b>-
Sulfuric Acid3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Acids
<div style="visibility:hidden">19504 19-504 504 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Acids Sulfuric Acid 504. A covered facility uses fuming sulfuric acid. This particular chemical is not listed as reportable under Section 313 of EPCRA, but it is chemically similar to sulfuric acid, which is reportable. Should the facility report if it meets threshold amounts and is a covered facility?Fuming sulfuric acid, more commonly known as oleum, is a mixture of sulfuric acid and sulfur trioxide. The facility must report on the acid aerosol forms of the sulfuric acid portion of the mixture in accordance with Section 372.30(b) if this portion exceeds the applicable threshold. The facility should also note that sulfur trioxide reacts rapidly with water to form sulfuric acid. Any sulfuric acid aerosol formed from sulfuric trioxide at the facility must be counted toward the manufacturing threshold. </div></b><div style="visibility:hidden"></div></b>-
Chemical Conversion; Coincidental Manufacturing; Combustion Byproducts; Hydrochloric Acid; Sulfuric Acid; Threshold Determination3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Acids
<div style="visibility:hidden">19505 19-505 505 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Acids Chemical Conversion (Activity Threshold); Coincidental Manufacturing (Byproduct; Coincidental Manufacture); Combustion Byproducts; Hydrochloric Acid; Sulfuric Acid; Threshold Determination (Activity Threshold) 505. A utility boiler, located at a covered facility, burns residual oil. As a result of the burning operation, the facility emits sulfur dioxide (SO2), sulfur trioxide (SO3), and particulate sulfates through a point source. Once emitted, the sulfur trioxide readily reacts with water vapor (both in air and in flue gases) to form a sulfuric acid mist. For purposes of EPCRA section 313, must the facility report on the generation of sulfuric acid?The sulfuric acid formed in the chemical reaction of sulfur trioxide and water that often occurs in the air after releasing sulfur trioxide is not included in threshold determinations. The facility owner/operator is not responsible for tracking or reporting on the formation of a listed toxic chemical once a chemical is released from a facility. However, if the reaction of sulfur trioxide and water takes place prior to being emitted (e.g., in the stack), the facility would be required to factor the quantity of sulfuric acid mist generated towards the manufacturing threshold. If the threshold is exceeded, the facility owner/operator must report all releases and other waste management estimates of sulfuric acid aerosols from the facility.</div></b><div style="visibility:hidden"></div></b>-
Coincidental Manufacturing; Hydrochloric Acid3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Acids
<div style="visibility:hidden">19506 19-506 506 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Acids Coincidental Manufacturing (Byproduct; Coincidental Manufacture); Hydrochloric Acid 506. Must a facility report itself as a manufacturer of hydrochloric acid aerosols, if the hydrochloric acid aerosol is formed in the stack?Yes, assuming thresholds are exceeded, the facility must report for hydrochloric acid aerosol. It is irrelevant where at the facility the acid aerosol forms. </div></b><div style="visibility:hidden"></div></b>-
Coincidental Manufacturing; Combustion Byproducts; Hydrochloric Acid; Metal Compounds3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Acids
<div style="visibility:hidden">19507 19-507 507 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Acids Coincidental Manufacturing (Byproduct; Coincidental Manufacture); Combustion Byproducts; Hydrochloric Acid; Metal Compounds 507. A covered facility has a coal-fired boiler. The combustion of the coal generates aerosol forms of hydrochloric acid as a byproduct. Should the aerosol forms of the HCl emissions be reported under EPCRA section 313?Yes. In the combustion of coal, the facility will be coincidentally manufacturing aerosol forms of hydrochloric acid, as well as hydrofluoric acid and sulfuric acid. The combustion of coal will also result in the coincidental manufacture of new metal compounds. The facility must submit a Form R if it manufactures more than a threshold amount of any of these listed toxic chemicals.</div></b><div style="visibility:hidden"></div></b>-
Acid Aerosol; Chemical Qualifier; Coincidental Manufacturing; Hydrochloric Acid3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Acids
<div style="visibility:hidden">19508 19-508 508 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Acids Acid Aerosol; Chemical Qualifier; Coincidental Manufacturing (Byproduct; Coincidental Manufacture); Hydrochloric Acid 508. Hydrochloric acid, also known as hydrogen chloride (CAS number 7647-01-0), is a toxic chemical under EPCRA section 313. Hydrochloric acid can exist in both aqueous solution and in a gaseous, anhydrous form. On July 25, 1996, EPA modified the listing of hydrochloric acid to include only acid aerosols including mists, vapors, gas, fog and other airborne forms of any particle size (61 FR 38600). Does the modified listing of hydrochloric acid refer to both the aqueous and the anhydrous forms of this chemical?Yes. The CAS number 7647-01-0 identifies both aqueous and anhydrous forms of hydrochloric acid. The listing modification also applies to both aqueous and anhydrous forms of hydrochloric acid.</div></b><div style="visibility:hidden"></div></b>-
Concentration Range; Waste Treatment; pH3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Acids
<div style="visibility:hidden">19510 19-510 510 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Acids Concentration Range; Waste Treatment; pH 510. Listed acids such as nitric acid are commonly used throughout the manufacturing sector as product ingredients, reactants, and chemical processing aids. Often, listed acids are present in aqueous waste streams that are neutralized on-site. If the listed acid is neutralized on-site, EPCRA section 313 requires an indication on the Form R of the range of concentration of the listed toxic chemical in the influent waste stream. These concentrations are expressed in percentages, parts per million (ppm), or parts per billion (ppb). If the pH of a waste stream containing a listed mineral acid is quantified, can the pH data be used to calculate the total mineral acid concentration in the influent waste stream?In cases where only one acid is present in solution, the total mineral acid concentration can be derived by using the pH value of the solution and the molecular weight and ionization constant of the acid. In order to assist the regulated community in EPCRA section 313 reporting, EPA derived a table that lists the total acid concentration for each listed mineral acid at different pH values (Estimating Releases and Waste Treatment Efficiencies for Mineral Acid Discharges Using pH Measurements (EPA 745/F-97-003), June 1991). The concentrations are expressed in pounds per gallon (lb/gal) and can be converted to the appropriate units for reporting purposes. The concentration that must be reported is based on the amount or mass of the toxic chemical in the waste stream compared to the total amount or mass of the waste stream. For example, assume that a facility treats, by neutralization, a waste stream containing nitric acid (HNO3) in which the pH of the influent stream is 4. A pH of 4 corresponds to a concentration of 0.000052 pounds of HNO3 per gallon of waste stream (Estimating Releases and Waste Treatment Efficiencies for Mineral Acid Discharges Using pH Measurements, Table 1). The amount of HNO3 in the influent waste stream can be converted using the following calculation: Influent waste stream: (0.000052 lb/gal) × (1 gal/3.78 L) × (453,000 mg/lb) = 6.2 mg/L of HNO3 in the waste stream Since mg/L of solutions or dispersions of a chemical in water is equivalent to ppm, 6.2 ppm of HNO3 is the concentration in the influent waste stream. The Form R requires a range of influent concentration, thus the facility should select the appropriate range code and enter that value in the Range of Influent Concentration column in Part II, Section 7A, the On-Site Waste Treatment Methods and Efficiency section of the Form.</div></b><div style="visibility:hidden"></div></b>-
Concentration; Nitric Acid3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Acids
<div style="visibility:hidden">19511 19-511 511 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Acids Concentration; Nitric Acid 511. How should nitric acid (CAS number 7697-37-2) be reported under Section 313? It does not exist in a pure or anhydrous form. Commercial nitric acid is produced at a concentration of 70 percent nitric acid in water.The listed CAS number for nitric acid specifically relates to the molecular formula HNO3. Therefore, facilities are required to count the amount of nitric acid in solutions toward thresholds and release and other waste management calculations. If 100 pounds of 70 percent nitric acid is released, the release should be reported as 70 pounds of nitric acid.</div></b><div style="visibility:hidden"></div></b>-
Aluminum; Combustion Byproducts; Treatment for Destruction3. Determining Whether or Not to Report: Listed Toxic Chemicals >
3.B. Toxic Chemical-Specific Questions-Acids
<div style="visibility:hidden">19521 19-521 521 2019 Questions and Answers Consolidation3. Determining Whether or Not to Report: Listed Toxic Chemicals 3.B. Toxic Chemical-Specific Questions-Acids Aluminum; Combustion Byproducts; Treatment for Destruction (Incineration) 521. At a covered facility, vapor is generated from molten aluminum. Upon exposure to the air at the temperatures present in the furnace, the aluminum vapor partially oxidizes and condenses to form aluminum fume. All stack emissions from the furnace are released as non-fibrous aluminum oxide. Should the release from this melting furnace be counted as aluminum fume or should the amount released be reported as zero since it is no longer a reportable toxic chemical?The facility is manufacturing aluminum fume, a listed EPCRA section 313 toxic chemical. In the furnace, the fume is then passively converted to non-fibrous aluminum oxide, a non-listed chemical. The facility is not actively destroying the aluminum fume. Therefore, the facility is not treating the toxic chemical for destruction. If the covered facility generates more than 25,000 pounds of aluminum fume during the course of the year, it would meet the manufacturing threshold for this chemical and would be subject to EPCRA section 313 reporting. Since there are no releases of the reportable chemical, the facility should report zero for release and other waste management activities for aluminum fume.</div></b><div style="visibility:hidden"></div></b>-
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